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Explanation of Metro2 Five Points of Compliance
The 5 Points of Metro2 Compliance
I am going to break down the 5 points of compliance for you here, some are pretty self-explanatory, however, others merit a much deeper look. So let us get to it, shall we?
- e-Oscar is a web-based, Metro2 compliant automated system: this is very important because Metro2 has been around for quite some time, however, it never really had any “teeth” to it until this phrase was added. This phrase simply stated that the bureaus are going to be Metro2 compliant. Now that it has been said…it must be followed. This was added officially in 2015.
- Credit Reporting Agencies (CRA’s) include Equifax, Experian, Innovis, and TransUnion, their affiliates or Independent Credit Bureaus and Mortgage Reporting Companies: e-Oscar also provides for Data Furnishers (DF’s) to send “out of cycle” credit history updates to CRA’s: What this means is that not only are the major CRA’s held to be Metro2 compliant but anyone they share information with…anyone. This is a huge deal for not only is the reporting to be Metro2 compliant, but also the companies who send information the CRA’s are to be compliant as well. Many more steps to prove compliance must be completed…and as you will see, this is going to prove to be IMPOSSIBLE!
- Automated Credit Dispute Verification (ACDV) initiated by a CRA on behalf of a consumer are routed to the appropriate DF based on the CRA and subscriber code affiliations indicated by the DF. Simply put, the CRA is required to forward all disputes to the DF who had reported the item to the CRA for verification. This also means that if a third-party reported this information, such as LexisNexis, they then have to forward the dispute to their source, i.e. SageStream. You can begin to see the mass amount of work required to get this done, and if you cannot, let me explain. See the major CRA’s have computers to do such things, others require individuals to complete this task. This creates a large demand for resources and quite frankly becomes overwhelming for them to complete when a simple deletion request is 100X easier, less expensive, and much faster to complete.
- The ACDV is returned to the initiating CRA with updated information (if any) relating to the consumer’s credit history: So, what happens is AFTER the DF has found what it has found, they then report it back to the requesting DF or requesting CRA with their findings. More steps for them to go through. If it was a third party DF, they return it to the DF that requested it to then update their files to then turn around and forward the findings to the originating CRA. WOW…here comes the part where it is virtually impossible to be 100% Metro2 compliant. Ready?
- If an account is modified or deleted, carbon copies are sent to each CRA with whom the DF has a reporting relationship: This is going to be a long paragraph or several…I will begin with what I consider the obvious.
CARBON COPIES? Are you kidding me? Metro2 Compliance mandates that carbon copies be sent out. Who the heck uses carbon copies of anything anymore? Car dealerships, sometimes I assume, but I cannot think of another place that would utilize carbon copies. OK, so let us say that they do have carbon copies, all they have to do is send them out to the major CRA’s right? NOPE!
They are required to send carbon copies to ALL places they have reporting relationships with that they have shared that reporting. This DOES NOT mean just for that one bureau, or for just the main 3 bureaus, but ANY data furnisher they do business with in regards to this client. This fact alone makes it virtually impossible to comply with Metro2 by itself, providing that the DF has carbon copies, even then…how would they construct hundreds of them for each and every individual that disputes or challenges an item on their credit profile?
Let us take this a bit further… Let us assume for the moment that they do have hundreds of carbon copies ready to be made… what would it cost them to mail them to each and every place they have a reporting relationship with? They cannot fax a carbon copy, they cannot email a carbon copy, they must send it via snail mail! USPS! Even with a high-volume discount from USPS, this quickly becomes something that drains and strains their resources. It is quite simply a million times easier for them to just admit defeat for the few that know about Metro2 and request to delete the item than to go through this process to prove compliance for Metro2.
Now, the last thing I want to say is this, and this is quite possibly the greatest aspect of it all. If the consumer were to sue the DF and or the CRA for non-compliance reporting of items on their credit report, they would win 100% of the time providing the consumer had proof that they challenged, and that the challenge was received. Because in a court of law, how is a DF or a CRA going to prove this to the court system? They cannot! The DF and the CRA’s know this and quite simply are not going to send their high-priced attorney into a courtroom knowing they will lose the case. They simply delete the item when they realize that the individual sending in the challenges knows what they are doing. End of story.
Challenging the Compliance
So, what do we do to challenge compliance? That is a great question, and I will tell you as much as I can without giving away proprietary information and highly guarded secrets.
Note that there are plenty of avenues we take in a precise order and timing. For you, the client, this next fact is great news! The simple fact that the majority of deletions come from the first 2-4 waves mean faster results, right? The next thing I am going to say is that, different from disputing, we WANT e-Oscar to handle ALL of our challenges, ALL OF THEM! Our letters are sent via fax (when a working known number is available), USPS is also used for the purpose of our working relationship, also great news for you!
The next thing I am going to say SHOULD NOT be expected, but we have seen great results within hours of sending in our letters of challenge (when the fax was successfully received by the bureaus) It can happen that fast. As a registered Credit Repair Organization (CRO), We cannot guarantee anything will happen, any deletions will occur, or that any score will go up. I can only comment on past experiences. That is the law. It also should be known that scores can and will go down initially on some credit files we work on. It is just the nature of the industry.
15-90 days is where our clients historically have seen the greatest results, awesome news for you!
So, there you have it, a complete rundown of what Metro2 Compliance is all about and why we do not and will not use disputing as a method of credit enhancement (repair).
I appreciate the time you took to read this. I hope that you learned something valuable, and if you have further questions, please contact us so we can clarify anything that you may have a question on.